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Who to regulate? Identifying actors within DeFi’s governance

Author

Listed:
  • Born, Alexandra
  • Gati, Zakaria
  • Lambert, Claudia
  • Naeem, Mahvish
  • Pellicani, Antonella

Abstract

Decentralised Finance (DeFi) emerged in 2021 as a fast-growing crypto segment, attracting policymakers’ attention due to its innovative approach of delivering financial services without relying on centralised intermediaries. This paper assesses DeFi governance arrangements for regulating and supervising DeFi using a comprehensive dataset. We find that governance token holders of four protocols (Aave, MakerDAO, Ampleforth, Uniswap) are highly concentrated with around half or more holdings linked to the protocols themselves or exchanges. Top voters are mostly delegates, who, in many cases, could not be identified nor linked to token holders. The study offers insights for policymakers regarding the implementation of policy measures aimed at bringing relevant entities under the regulatory umbrella. The difficulty in identifying holders and voters using public data may make it hard to rely on some of the regulatory anchor points often put forward in the policy debate such as governance token holders, developers or centralised exchanges. JEL Classification: G18, G23, G28, O33

Suggested Citation

  • Born, Alexandra & Gati, Zakaria & Lambert, Claudia & Naeem, Mahvish & Pellicani, Antonella, 2026. "Who to regulate? Identifying actors within DeFi’s governance," Working Paper Series 3208, European Central Bank.
    • Handle: RePEc:ecb:ecbwps:20263208
    Note: 1559770
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    JEL classification:

    • G18 - Financial Economics - - General Financial Markets - - - Government Policy and Regulation
    • G23 - Financial Economics - - Financial Institutions and Services - - - Non-bank Financial Institutions; Financial Instruments; Institutional Investors
    • G28 - Financial Economics - - Financial Institutions and Services - - - Government Policy and Regulation
    • O33 - Economic Development, Innovation, Technological Change, and Growth - - Innovation; Research and Development; Technological Change; Intellectual Property Rights - - - Technological Change: Choices and Consequences; Diffusion Processes

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